ICD-10: It’s all About Your Perspective

“It was the best of times, it was the worst of times, it was the age of wisdom, it was the age of foolishness, it was the epoch of belief, it was the epoch of incredulity, it was the season of Light, it was the season of Darkness, it was the spring of hope, it was the winter of despair…” -Charles Dickens

The recent National Committee on Vital and Health Statistics (NCVHS) testimony by key industry stakeholders demonstrated again how much we are all in agreement on critical points: we need an ICD-10 implementation date that’s certain (not a “maybe next year”), adequate end-to-end testing must happen soon for successful implementation, costs for some smaller practices and organizations may be insurmountable, resources are being lost or diverted, many physicians are disengaging, and credibility of many in a position of authority has gone right out the window.

There were other messages, too: many believed that they were ready for a 2014 implementation, there is increasing focus on the little guys, coding is not that difficult if you have good clinical documentation, coding productivity losses may not be as bad as anticipated, costs might be lower than projected for some practices, vendors are focused on ICD-10 products, published future Centers for Medicare & Medicaid Services (CMS) ICD-10 coverage policies are comparable in coverage to the ones in effect today (including all the non-specific codes), and there have been a few successful end-to-end testing stories to tell.

Regardless of which perspectives we hold, the one matter that spawned nearly universal incredulity was the Congressional Budget Office cost estimate of $0 impact for this delay. Make no mistake, there are significant looming costs for our organizations, businesses, and practices. Just a partial financial impact list includes training for new coders who only just learned ICD-10, costs associated with maintaining proficiency in a coding system you are not currently using, reprogramming systems and electronic health records, re-staffing, rehiring and retraining, etc.

The other financial reality is that many organizations’ and practices’ resources that were allocated for ICD-10 in 2014 now are being diverted to other pressing needs. It is hard to make a cogent argument against slowing and/or diverting resources when 2015 is simply the next planned implementation date, not a certain one. Once momentum has been lost, it is difficult to rebuild it.

These messages are not new, and we hope everyone invested in ICD-10 is really listening. Collectively, they are the voices of industry experience and unparalleled expertise.

If we assume that Oct. 1, 2015 could be the real implementation date, what should or could we be doing right now?

We should acknowledge our credibility problem. When I talk with my physicians, I can relate to the famous line from the Marx brothers: “Who are you going to believe, me or your lying eyes?” No, we can’t guarantee that Oct. 1, 2015 will be the day. But we can help them with reasonable, common-sense steps such as improving documentation.

We should not squander the extra time by delaying full end-to-end testing until 2015. This is a golden opportunity to leverage a full year or more of meaningful testing to ensure that claims will be adjudicated as expected, that no significant failures will occur, that vendor products will function as promised, and that payments will not be delayed or disrupted. It allows us time to test with many more payors, facilities, and practices rather than limiting testing to small groups of specific stakeholders. It also provides the ability to reassure the industry that implementation will go smoothly. It allows time for remediation of identified problems. Lastly, it will provide the live claim environment and true readiness assessment that syntax-only testing, such as that which the MACs conducted in March, cannot replicate. The published intent by some payors to delay testing until well into 2015 will almost certainly recreate the problems that have resulted in the last two delays. I believe that if payors represented that they were ready for Oct. 1, 2014, there is no credible or compelling reason to delay testing until 2015.

CMS should establish a small practice/entity/organization workgroup that focuses on ways to support and assist those at greatest risk due to limited financial and administrative resources.

None of these recommendations are new. The majority of the testimony from NCVHS was consistent with previous key messages. The issues we have now are the ones we predicted. The solutions are the same ones we have recommended for three years. The newest delay causes plenty of problems, but it also creates plenty of golden opportunities.

We need to embrace them and use them to our advantage.

Disclaimer: Every reasonable effort was made to ensure the accuracy of this information at the time it was published. However, due to the nature of industry changes over time we cannot guarantee its validity after the year it was published.

Holly Louie is the compliance officer for Practice Management Inc., a multi-specialty billing company in Boise, Idaho. Holly was the 2016 president of the Healthcare Business and Management Association (HBMA) and previously chaired the ICD-10 Committee. Holly is also a national healthcare consultant and testifying expert on matters related to physician coding, billing, and regulatory compliance. She has previously held compliance officer positions in local and international billing companies. Holly is a member of the ICD10monitor editor board and a popular guest on Talk Ten Tuesdays.

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